Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

In this dispute between an Insurer and pension holders, the Second Circuit granted in part and denied in part Insurer's motion to dismiss. Plaintiffs did not timely appeal from the district court’s orders addressing the methodology for computing individual relief, so the court lacked jurisdiction over that portion of Plaintiffs’ appeal. However, the court found that it had jurisdiction over the portion of Plaintiffs’ appeal challenging the district court’s order denying sanctions. Considering that order on the merits, the court concluded that it was not an abuse of discretion and affirmed. View "Amara v. Cigna Corporation" on Justia Law

In 2017, Congress passed an amendment to the statute setting forth quarterly fees in bankruptcy cases, 28 U.S.C. Sec. 1930. The 2017 Amendment increased quarterly fees in judicial districts in which the United States Trustee Program oversees bankruptcy administration.Debtors challenged the Bankruptcy Court's ruling rejecting their constitutional challenge to quarterly fees imposed during the pendency of their bankruptcy proceeding. The Bankruptcy Court rejected Debtors’ argument that the 2017 Amendment violated the uniformity requirement of the Bankruptcy Clause of the United States Constitution.The Second Circuit reversed, finding the 2017 Amendment is a bankruptcy law subject to the uniformity requirement of the Bankruptcy Clause. The court also held that, under the version of Sec. 1930 in effect prior to the 2020 Act, the 2017 Amendment violated the uniformity requirement. View "In re Clinton Nurseries" on Justia Law

Plaintiffs brought various claims against Rockland County ("Rockland County Defendants") officials including a violation of the Free Exercise Clause of the First Amendment, based on orders which excluded children who were not vaccinated against measles from attending school and an emergency declaration which barred unvaccinated children, other than those with medical exemptions, from places of public assembly. The district court granted summary judgment for Rockland County Defendants.The Second Circuit reversed, finding that Plainitffs' claim raises numerous disputes—including whether there is evidence of religious animus, to whom the emergency declaration applied, and what the County’s purpose was in enacting the declaration—that prevent Defendants from prevailing on summary judgment. View "M.A. v. Rockland County Department of Health" on Justia Law

An immigration judge (“IJ”) denied Petitioner’s application for asylum, withholding of removal, and protection under he Convention Against Torture based on his failure to adequately corroborate his claim with documentary evidence. The Board of Immigration Appeals (“BIA”) affirmed. Petitioner argued that the BIA was unduly deferential to the IJ’s determination that corroboration was required.The Second Circuit denied the petition for review. The court held that the BIA reviews de novo an IJ’s determination under 8 U.S.C. Section 1158(b)(1)(B)(ii) that an applicant should provide additional evidence that corroborates otherwise credible testimony, because that is not a finding of fact. In contrast, the BIA reviews for clear error an IJ’s finding as to whether an applicant does not have and cannot reasonably obtain such corroborating evidence because that is a finding of fact. Here, the court explained that the BIA properly applied de novo review to the IJ’s request for corroborating evidence and properly reviewed for clear error the IJ’s finding that Petitioner failed to produce requested evidence that he could reasonably have obtained. View "Pinel-Gomez v. Garland" on Justia Law

Petitioner petitioned for review of a Board of Immigration Appeals (BIA) decision affirming an Immigration Judge’s denial of his application for asylum and withholding of removal under the Immigration and Nationality Act and protection under the Convention Against Torture (CAT). Petitioner argued that the agency erred in denying his withholding of removal claim when it required that he demonstrate that his ethnicity was “at least one central reason” motivating his claimed persecution. He also challenges the BIA’s denial of his asylum claim and its finding that he waived his CAT claim.   The Second Circuit denied the petition. The court held that the withholding of removal statute is ambiguous as to the showing required to establish that a protected ground, such as ethnicity, motivated a persecutor. The court also held that the BIA’s interpretation that the “one central reason” standard applies to withholding of removal claims is reasonable and thus entitled to deference.   The court explained that substantial evidence supports the BIA’s determination that Petitioner did not demonstrate a link between his ethnicity and future persecution. Although Petitioner’s brother, who is in the United States, declared that the family “still received threatening messages,” his mother, who continues to live in Ecuador, did not corroborate this statement. She stated that her life would be at risk not because of threats or harm from the gang, but because if Petitioner were to return, he would be unable to support her. View "Quituizaca v. Garland" on Justia Law

Plaintiff appealed from a district court judgment granting Defendants’ motion to dismiss her complaint. n relevant part, the district court found wanting her claims for fraud in the enforcement of a mortgage; fraud upon the court; collusion and deceit upon the court in violation of New York State Judiciary Law Section 487; and negligence. It explained that it was precluded by the Rooker-Feldman doctrine from adjudicating all of Plaintiff’s claims, and that, in any event, principles of res judicata and estoppel barred her from pursuing these claims.   The Second Circuit affirmed in part the district court’s judgment dismissing Plaintiff’s fraud and negligence claims against the Attorney Defendants and vacated in part the dismissal of her claims under New York Judiciary Law Section 487. The court concluded that the Rooker-Feldman doctrine does not require the dismissal of Plaintiff’s claims; that res judicata does not bar her claims, and that collateral estoppel bars her fraud and negligence claims, but not her section 487 claim for deceit upon the court View "Hansen v. Miller" on Justia Law

Defendants appealed from an order denying their motion to dismiss in part and rejecting their qualified immunity defense against the Religious Freedom Restoration Act ("RFRA") claims of Plaintiffs. Plaintiffs are practicing Muslims whose religion requires them to perform daily congregational prayers with as many other Muslims as are available. According to the allegations in their complaint, while Plaintiffs were incarcerated at the Federal Correctional Institution in Danbury, Connecticut, Defendants enforced a policy that restricted group prayer to the prison's chapel, despite that facility's frequent unavailability. As a result, Plaintiffs were forced to forgo their religious exercise of group prayer to avoid disciplinary action.   The Second Circuit affirmed the district court’s order. The court concluded that the wardens are not entitled to qualified immunity at this stage of the proceedings because the pleadings do not establish that their enforcement of the policy against Plaintiffs was in service of a compelling interest, and it was clearly established at the time of the violation that substantially burdening an inmate's religious exercise without justification violates RFRA. View "Sabir v. Williams" on Justia Law

Plaintiff brought an employment action claiming that his employer, Salisbury Bank and Trust Company (the "Bank") discharged him in violation of New York Labor Law Section 201-d because he chose to campaign for election to a seat in the New York State Assembly. The district court granted the Bank's motion for summary judgment, holding that Plaintiff voluntarily resigned and was not constructively discharged.   On appeal, Plaintiff made two principal arguments. First, he contends that the Bank unlawfully "forced" him to decide between "termination or his protected political activity" and that, as a result, his departure from the Bank was involuntary. Second, he argued that the Bank has only proffered as a reason for its actions his statutorily "protected political activities."   The Second Circuit vacated the district court’s judgment. The court explained that even though the Bank claims that it had not decided to discharge Plaintiff when it learned of his "Decision," on this record a reasonable jury could find that the Bank had already concluded that Plaintiff would be discharged if he did not give up his campaign. For these reasons, a reasonable jury could find that Plaintiff suffered an adverse employment action by being forced to choose between his campaign and his job in violation of New York Labor Law. Further, a reasonable jury could find that the Bank's actions violated New York Labor Law Section 201-d because the bank failed to demonstrate a legitimate, nondiscriminatory reason for the adverse employment action it took against Plaintiff. View "Truitt v. Salisbury Bank and Trust Co." on Justia Law

Plaintiff, as a receiver for debtor FutureNet Group, Inc., sued FutureNet’s judgment creditors – GTR Source, LLC (“GTR”) and Capital Merchant Services, LLC (“CMS”) – and the New York City Marshal for allegedly violating New York’s procedural rules when they executed state-court judgments against FutureNet. In the action against GTR and the Marshal, the district court dismissed Plaintiff’s claims, concluding principally that FutureNet would not suffer any injury even if the executions and levies were procedurally defective, since the seized property was used to satisfy valid underlying judgments. In a similar action against CMS, the district court dismissed the suit based on issue preclusion, finding that Plaintiff’s claims hinged on the same question of law at the heart of the GTR case. The district court also held that, absent preclusion, dismissal was appropriate because FutureNet suffered no damages. Plaintiff was subsequently replaced by two of FutureNet’s senior creditors, Plymouth Venture Partners, II, L.P. and Plymouth Management Company, which now challenge both district-court decisions.   Now guided by the New York Court of Appeals’s decision that Article 52 of the CPLR is a judgment debtor’s exclusive avenue for relief from a procedurally defective execution and levy, the Second Circuit affirmed the district courts’ judgments dismissing Plaintiffs’ actions. The court explained that the New York Court of Appeals unequivocally held that a judgment debtor must “bring an appropriate action pursuant to CPLR 12 Article 52” for relief from a procedurally defective execution and levy. Here, FutureNet has not done so. Thus, the court affirmed the district court’s dismissal. View "Plymouth Venture Partners, II, L.P. v. GTR Source, LLC; Cap. Merch. Servs.," on Justia Law

Plaintiff Aetna Life Insurance Company brought suit against Big Y Foods, Inc., for reimbursement of Aetna's payments for medical services on behalf of a woman after she was injured at a Big Y Foods, Inc. supermarket store. Aetna moved for partial summary judgment, arguing that the Medicare Secondary Payer Act gave Medicare Advantage organizations such as Aetna a private cause of action to seek reimbursement of conditional payments for medical services from tortfeasors such as Big Y and that no genuine issue of material fact remained. The district court granted Aetna's motion, and Defendant appealed.
The Second Circuit affirmed concluding that the Medicare Secondary Payer Act grants a private cause of action to Medicare Advantage organizations such as Aetna and that no genuine issue of material fact remains. Big Y argued that even if Aetna has a private cause of action under the MSP Act, there are genuine issues of material fact remaining as to whether Big Y has the responsibility to reimburse Aetna for the medical expenses Aetna incurred. The court wrote that Big Y's argument is directly contradicted by the statute. Further, Big Y does not dispute that the victim filed a claim against Big Y seeking compensation for the personal injuries that she sustained; that Big Y settled that claim with the victim paying her $30,000; and that Big Y knew that Aetna was asserting a lien against Big Y for Aetna’s payment of the woman’s medical expenses. Thus, Big Y is responsible for payment as a matter of law. View "Aetna Life Insurance Company v. Big Y Foods, Inc." on Justia Law